CbCR in the Czech Republic for the first time

As we informed you in our previous news briefing, taxpayers are now obliged to submit a “Country-by-Country Report” (the “CbCR”) to the tax authorities. For your benefit, here is our basic overview of the issue.

What?

The answer seems obvious, yet is not. The amendment to the Act on International Cooperation in Tax Administration introduces two terms – an announcement (oznámení) and a notification (ohlášení). Whilst an announcement also includes the above Country-by-Country Report, a notification has merely informative value. Tax authorities are informed by a notification which entity is obliged to submit a CbCR.

Who?

If the income of a group of companies exceeded EUR 750 million in 2015, there is an obligation to submit a CbCR to the tax authority for 2016. As a rule, only the reporting entity in the group submits a CbCR. The other entities only identify the reporting entity of the group that will submit a CbCR through a notification submitted to the tax authority.

When?

The notification shall be submitted by 30 October 2017 at the latest. The announcement including a CbCR shall be submitted within 12 months of the end of the relevant reporting period.

How?

Only electronic submission is possible for both an announcement and a notification. The forms will be available in the tax portal of the tax administration (EPO). Submission shall be possible after adding a digital signature or through a data box.

Problems?

As with any other issue, our tax advisors can help you prepare the required submissions. If you need any advice or assistance in filling in any of the forms, please feel free to contact our tax advisors any time. We are also, of course, ready to help you to assess whether a specific group of companies is or is not subject to CbCR.